Privacy

WEBSITE PRIVACY STATEMENT

Fast Pay Partners LLC and its affiliated and subsidiary companies (“FastPay”, “we”, “us”, and “our”) respect your privacy and are committed to protecting your personal data. This Privacy Statement describes how we look after your personal data:

  1. when you visit or use our website or any of our software applications (the “Sites”) regardless of where you visit or use the Sites from; and/or
  2. which we otherwise receive or collect from you in the course of our operations and client services (including using our products and services).

It also describes certain privacy rights and data protection laws that may apply to you.

It is important that you read this Privacy Statement together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting and/or processing personal data about you so that you are aware of how and why we are using your data. This Privacy Statement supplements other such notices and is not intended to override them.

 

DATA CONTROLLER

For the purposes of data protection under the General Data Protection Regulation and any applicable national implementing laws, regulations, secondary or other legislation (collectively, the “GDPR”), the legal entities overseeing the processing of your personal data are:

  1. Fast Pay Partners LLC of 8201 Beverly Blvd. Ste 600, Los Angeles, CA 90048 (the “Primary Address”)
  2. FPP Capital LLC of the Primary Address
  3. FPP Sandbox LLC of the Primary Address
  4. FPP Finance LLC of the Primary Address
  5. AO Holding Co. of the Primary Address
  6. FP Services Inc. of the Primary Address
  7. FastPay Payment Technologies Inc. of the Primary Address
  8. FastPay Roundabout Limited of Second Floor, 11 Pilgrim Street, London, EC4V 6RN

To clarify the essence of the arrangement by which FastPay collects and processes personal data, all the legal entities above are considered data controllers in their own right. On occasion, for certain processing activities, one of the entities may act as a data processor for another. There may also be processing activities for which we would be considered joint data controllers in that we may jointly determine the purposes and means by which your personal data is processed by us.

For purposes of the GDPR, Fast Pay Partners LLC, FPP Capital LLC, FPP Sandbox LLC, FPP Finance LLC, AO Holding Co., FP Services Inc., and FastPay Payment Technologies Inc. in their capacity as controllers of processing activities that are subject to the GDPR, identifies FastPay Roundabout Limited of Second Floor, 11 Pilgrim Street, London, EC4V 6RN as its establishment in the EU and designates the individual below as its EU representative and data privacy manager.

FastPay has appointed the following individual as its data privacy manager:

Data Privacy Manager

FastPay

8201 Beverly Blvd. Ste 600

Los Angeles, CA 900487

If you have any questions about this Privacy Statement, including any requests to exercise your legal rights (see below), please contact the data privacy manager using the details set out above.

 

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

FastPay will only collect personal data required to serve the purpose for which it was collected. The type of personal data we collect will depend upon the nature of your relationship with us (e.g., whether you are a client, prospective client, job candidate, service provider, or visitor to the Sites or our premises), the purpose for which the data is required, and our legal and regulatory obligations.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

FastPay will collect your personal data in a number of ways, including when you contact us or register with us through the Sites, or by telephone, post, or e-mail.

Further information

Clients

As a client of ours, or a client’s employee or representative, the information we collect from you may include the following:  

  • contact details (including names, postal addresses, email addresses and telephone numbers);
  • professional information such as job title and employer/company;
  • credit card or debit card details if you make a purchase or pay subscription fees for product(s) or service(s);
  • bank account details in order to provide our loan services to your employer;
  • your username and password for your online account;
  • information about the product(s) or services you or your employer wish to obtain from us and you or your employer’s use of the product(s) or services;
  • details regarding your attendance at FastPay’s events;
  • health-related information (such as dietary requirements, disability access, medical conditions, etc.) in connection with your participation at our events; and
  • information as required by regulatory “know your client,” anti-money laundering or proceeds of crime legislation — some of this information we may request or obtain from third-party sources.

Prospective clients

As a prospective client or employee or representative of a prospective client for FastPay, the information we collect from you may include the following:

  • contact details (including names, postal addresses, email addresses and telephone numbers);
  • professional information such as job title and employer/company;
  • nature of your or your employer’s interest in our product(s) and service(s);
  • information about the product(s) and service(s) you or your employer may wish to obtain from us.
  • details regarding your attendance at FastPay’s events;
  • health-related information (such as dietary requirements, disability access, medical conditions, etc.) in connection with your participation at our events; and
  • information as required by regulatory “know your client” and or anti-money laundering or proceeds of crime legislation. Some of this information we may request and/or obtain from third party sources.

Job candidate

As a job candidate looking to join FastPay, the information we collect from you for recruitment purposes may include the following:

  • contact details (including names, postal addresses, email addresses and telephone numbers);
  • information regarding your criminal and disciplinary records (if any), including from background checking authorities, agencies and any regulators;
  • details of your references;
  • information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers;
  • information regarding your academic and professional qualifications;
  • your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information; and
  • a copy of your driver’s license or other suitable documentation to identify you and verify your identity.

Providers/suppliers

We collect limited information that could be considered personal data from providers of services or suppliers to FastPay. The information we collect from you may include the following:

  • your name and contact details (i.e., address, landline and mobile phone numbers, email address);
  • bank account details, should we need to transfer funds to you.

Users of the Sites

As a user of the Sites or any other website or web address operated by or on behalf of FastPay that links to this Privacy Statement, we collect information that you submit to us when you interact with features of the Sites such as logging into your account. When you do this we may collect:

  • your name and contact details (i.e., address, home and mobile phone numbers, email address);
  • your username and password;
  • your credit/debit card details for payment purposes;
  • anything you download from the Sites; and
  • any information that you input into the Sites.

In addition to collecting information, we collect analytics relating to your time spent on the Sites. We collect the following information:

  • your internet protocol (IP) address; your login data, browser type and version; time zone setting and location; browser plug-in types and versions; operating system and platform; and other technology on the devices you use to access the Sites.

More information can be found within our Cookies Policy.

Our Sites are not intended for children and we do not knowingly collect data relating to children via the Sites.  

Visitors to our premises

As a visitor to FastPay’s premises, we may capture the following information about you:

  • contact details (including names, postal addresses, email addresses and telephone numbers);
  • images captured by our premises’ CCTV cameras.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your data relating to your use of this website to calculate the percentage of users accessing a specific website feature. However, if we combine or connect such data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Statement

Third-Party Analytics

FastPay’s online portals may, from time to time, utilize third-party analytics systems (including but not limited to FullStory) to help improve usability and the customer experience.  Such systems may record mouse clicks, mouse movements and scrolling activity. Such systems may record keystroke information that you voluntarily enter on this website. Such systems do not track this activity on any site that does not use such systems.  With respect to FullStory, you can choose to disable such service at https://www.fullstory.com/optout/. Note, that doing so will disable other features and services of such FullStory system that our sites may, from time to time, employ such as 1-to-1 support chat or troubleshooting service support.

 

WHY DO WE COLLECT PERSONAL DATA FROM YOU?

FastPay collects and processes your personal data in connection with its business and to pursue our related legitimate interests and rights, including the promotion and marketing of our products and services.

The personal data we collect is processed in compliance with relevant data protection laws and regulations.

Further information

Purpose and legal basis for processing

When processing your personal data, the purpose and legal basis include the following, to the extent that they apply to you:

  • to perform client services to fulfil our contractual obligations toward you or your employer, and on the basis of our legitimate interests, or our clients’ legitimate interests, to provide the best client service we can;
  • to support our business processes including our information technology, electronic communications and electronic documents storage, management and transmissions, to fulfil our contractual obligations toward you or your employer, or, if not applicable, on the basis of our legitimate interests to provide the best client service we can, to support our business operations, administration, IT services, and network security, and to prevent fraud;
  • to safeguard your personal data and our IT system with appropriate security, on the basis of your and our legitimate interest for such security;
  • to exchange information, conduct due diligence, and answer your initial questions, to take steps required to enter into a contract with you or your employer, or, if not applicable, on the basis of your consent;
  • for our recruitment purposes, including in the context of a selection and recruitment procedure, to take steps prior to entering into an employment relationship or contract with you or on the basis that it is our legitimate interest to use your personal data in such a way to ensure that we can make the best recruitment decisions — we will not process any special categories of personal data except where we are able to do so under applicable legislation or with your explicit consent;
  • to keep you up-to-date with news that may be of interest to you, on the basis of your consent or our legitimate interests to use your personal data for marketing purposes;
  • to present the Sites and its content in the best possible way for you and on your computer, on the basis of our legitimate interests to keep the Sites updated and relevant, to develop our outreach and business operations, and to develop marketing strategy;
  • for business transactions such as a merger, acquisition by another company, or sale of all or a portion of our assets on the basis of our legitimate interests to sell or expand our business operations; and/or
  • to comply with legal and regulatory requirements applicable to us (including the need to prevent and combat money laundering).

Where the processing of your personal data is based on your consent only, you have the right to withdraw this consent at any time. We will then erase your personal data and stop processing it.

Marketing

You may receive marketing communications from us if you are an existing client or if you provided us with your consent or where we are pursuing a legitimate interest and have a lawful right to do so and, in each case, you have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by contacting marketing-optout@gofastpay.com at any time.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 

HOW LONG DO WE KEEP YOUR DATA?

Your personal data is kept for the time required to pursue the purposes for which it was collected and processed, including for the purpose of satisfying any applicable legal, professional, contractual, regulatory, accounting or reporting requirements.

If you request that we stop sending you marketing materials, we will continue to keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.

Further information

We will retain your personal data only for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, legitimate administrative or operational purposes, and any reporting requirements. In determining data retention periods, we take into consideration local laws, contractual obligations, our reasonable business requirements, and your expectations and requirements.

When it is no longer necessary to retain your personal data, we will securely delete or, in some circumstances, anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further statement to you.

 

SHARING YOUR PERSONAL DATA

To provide our products and services and effectively run our business, we need to share your personal data. Transfer of personal data will occur to:

  • third party service providers we retain, such as vendors and suppliers;
  • our US-based offices and to third party service providers used by our US offices; and
  • public and regulatory bodies in the event we are required to do so.

Some of these transfers will involve international transfers of your personal data outside the European Economic Area (“EEA”) and data centers or those of our service partners or public and regulatory bodies.

Further information

Categories of recipients

Your personal data may be transferred to the following categories of recipients:

  • vendors, suppliers or other third parties FastPay retains in connection with the provision of our products and services as required to obtain the services we need to operate our business or to provide products and services to our clients;
  • FastPay’s US offices; and
  • public authorities if we are required to do so by law or legal process, in response to a request from government authorities, or if we believe disclosure is necessary to prevent personal harm or financial loss.

We reserve the right to transfer your personal data in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will require that the transferee use personal data you have provided in a manner consistent with this Privacy Statement and the applicable legal framework.

International transfers of your personal data

FastPay is based in the United States, which is outside the EEA. We allow different FastPay offices to access your personal data, and may allow access to your personal data, or parts of it, to our service providers required to obtain the services we need to operate our business or to provide services to our clients. Our third-party service providers may also be based outside the EEA.

Whenever we transfer your personal data out of the EEA, where required by law, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism we use when transferring your relevant personal data out of the EEA.

 

HOW DO YOU PROTECT MY PERSONAL DATA?

FastPay employs industry-standard best-practice protection to safeguard the personal data it collects.

Further information

FastPay has implemented appropriate technical and organisational methods to protect the personal data we hold from loss, misuse, or unauthorised access, including safeguarding such data with AES256 encryption and also managing such data utilizing a secure private infrastructure.

The Sites are designed to secure the personal data you provide on computer servers in a controlled, secure environment. When personal data (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption.

 

WHAT RIGHTS DO I HAVE IN RELATION TO MY PERSONAL DATA?

Depending on the facts and circumstances related to the personal data we collect or obtain about you – including, for example, the nature of the information we process or where you are located or reside – you may have rights regarding the personal data we hold about you afforded under the GDPR. These may include the right to request information about, or access to, the personal data we hold, and rights to complain about how we handle your personal data. FastPay is committed to honoring rights you have been afforded under data protection laws while ensuring that such rights are exercised in accordance with our other legal and ethical obligations.

Further information

Right to request

Under certain conditions, you may have the right to request from FastPay, among other things:

  • access to certain information concerning your personal data and the way we are processing it;
  • rectification of inaccurate or incorrect personal data;
  • erasure or restriction of inaccurate, incorrect personal data or personal data unlawfully processed;
  • to stop certain processing, at any time, on grounds relating to your particular situation, including profiling, and to stop any processing, at any time, where it relates to direct marketing; and
  • to receive your personal data in a structured, commonly used and machine-readable format, enabling you to transmit the personal data to another data controller.

For more information on the full extent of your rights or to exercise your rights, please contact our data privacy manager by mail at the addresses indicated above with a brief explanation of your request. When exercising any of those rights, please let us:

  • have enough information to identify you;
  • have proof of your identity and address (a copy of your driver’s license or passport and a recent utility or credit card bill); and
  • know the information to which your request relates.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

If you would like to unsubscribe from any email publication you can also click on the ‘unsubscribe’ button at the bottom of the relevant email publication. It may take up to 10 business days for this to take place.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Right to complain

We hope that we can resolve any query or concern you raise about our use of your personal data. However, if you believe your personal data is unlawfully processed by FastPay under applicable data protection laws, you may lodge a complaint with the Information Commissioners Office (the UK’s supervisory authority for data protection): https://ico.org.uk

 

WHAT IF I DO NOT WANT TO PROVIDE MY PERSONAL DATA?

For clients, prospective clients, job candidates and providers, it is in your discretion to provide personal data to us. However, for us to enter into a contract with you or your employer, or other professional, employment or business relationship with you, we will need to obtain certain information, including personal data that may be necessary or legally required. If you do not provide us with all or some of the personal data we request, we may be prevented from entering into a contract with you, providing you with services, or sending you marketing information or other communications that you have requested.

For users of the Sites, providing your personal data is purely voluntarily. Not providing such data may only prevent you from receiving information from FastPay. Analytical information captured when you use our products or services, access your account and/or visit the Sites is described in our Cookies Policy, which you can review here.

 

AMENDMENTS TO THIS PRIVACY STATEMENT

FastPay may update this Privacy Statement from time to time, and we reserve the right to do so to comply with applicable data protection laws. The effective date of this Privacy Statement is noted at the top of this page. We encourage you to review this page periodically. If we make material changes to the way that we collect, use or share personal data that you have provided, we will post the revised Privacy Statement on the Sites.